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2023 (5) TMI 919 - SCH - Income TaxReopening of assessment - Deemed dividend - addition u/s 2(22)(e) - change of opinion - information received from the Deputy Commissioner of Income Tax, Company Circle V(1) constituted new information - HC [2018 (10) TMI 373 - MADRAS HIGH COURT] decided substantial question of law in favour of revenue - HELD THAT:- Appeal admitted - List immediately after summer vacations. Deemed dividend addition u/s 2(22)(e) - Addition on account of income from house property as per the provisions of Section 22 read with Section 23 and Addition u/s 40A - HC [2019 (1) TMI 1017 - MADHYA PRADESH HIGH COURT] held assessee being not a member/shareholder of the concerned company the loan/advance received from such company is not deemed dividend u/s 2(22)(e) - payments made to specified persons on rates more that fair market rates - As per HC no substantial question of law arises for consideration - Revenue appeal dismissed - HELD THAT:- In terms of Circular No. 17/2019 dated 08.08.2019 issued by Government of India, Ministry of Finance, Department of Revenue, Central Board Direct Taxes, Judicial Section, since the amount of tax involved is low, we are not inclined to interfere with the impugned order. SLP dismissed.
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